STATE OF U.P. vs JAI BIR SINGH

The Supreme Court addressed the conflict between two prior judgments regarding the definition of 'industry' under Section 2(j) of the Industrial Disputes Act, 1947, specifically in relation to the 'Social Forestry Department'. The Court held that the expansive interpretation of 'industry' from the Bangalore Water Supply case is not warranted, emphasizing that not all welfare activities by the State qualify as 'industry'. The judgment clarifies the scope of 'sovereign functions' and the legislative intent behind the definition, ultimately reaffirming the need for a more restricted interpretation of 'industry'.